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Fact Sheet

Illinois Regulatory Requirements for Management of Fluorescent and High Intensity Discharge Lamps

Illinois House Bill (HB) 2164 became law on August 19, 1997,exempting only householders. This law designates fluorescent and high intensity discharge (HID) lamps as universal waste, a category of hazardous wastes, because of their mercury content. This designation dramatically changed your allowable management practices for these lamps. Most notably, as universal waste lamps, they no longer must be disposed of in hazardous waste landfills as long as they are properly recycled or pass the TCLP test. The universal waste designation allows the lamps to be handled with less paperwork and licensing. While they may not be disposed of in municipal landfills or incinerators in Illinois unless they pass TCLP testing, they are easier to process to a recycler for destruction.
HB 2164 required the Illinois Environmental Protection Agency to propose revisions to Title 35, Part 733 of the Illinois Administrative Code for management of lamps. The revisions to these regulations, which are often called the Universal Waste Regulations, were promulgated as final on April 2, 1998. Under the regulations, lamps which are characteristically hazardous because of mercury content become a universal waste as soon as they are permanently removed from service, i.e., when a spent lamp is removed from a fixture. The regulations identify “roles” in the subsequent management of the lamps and standards applicable to these roles. You, as the building owner or tenant, will be involved in one or more of these roles, as explained below.


The regulations identify generators, handlers (small and large quantity), transporters, and destination facilities. Which hats you wear depends on what involvement you have in the lamp management process. As the building owner or tenant you are a universal waste generator. If you remove the lamps you are also a handler, either a small or large quantity handler. If you subsequently transport the material off-site then you are also considered a transporter. It is unlikely that building owners or tenants would be a destination facility, unless you enter the lamp recycling business. A building management company or a contractor that re-lamps or removes lamps from a building also takes on roles in this process. An outside company that removes lamps is a handler. If the company transports the lamps off-site, they are a transporter.


So, what do you need to do as a generator, handler, and/or transporter? Fortunately, the universal waste designation is intended to minimize your regulatory requirements. As noted, you can no longer dispose of spent lamps in municipal landfills or incinerators in Illinois, regardless of the number of lamps you generate. The most viable option is to “dispose” of the lamps by recycling. The regulatory requirements for properly managing the lamps to a recycler are briefly summarized below.


Generators do not have specific regulatory requirements per the Universal Waste Regulations. However, generators may also be handlers as described above. Furthermore, and more importantly, generators ultimately have responsibility for ensuring their lamps are properly managed/destroyed. IE Cradle to grave responsibility.


Universal waste handlers must:

    1. Handle lamps in a manner that prevents releases (breakage).
    2. Put unbroken lamps in containers that minimize breakage and put broken lamps in packaging that prevents mercury vapor releases.
    3. Immediately contain any releases and manage released material as a hazardous waste unless it is determined not to be hazardous.
    4. Label all lamp containers.
    5. Only ship the lamps to another universal waste handling facility or a universal waste destination facility such as Fluorecycle, Inc.
    6. If the facility is a large quantity handler, notify the Illinois Environmental Protection Agency (IEPA) of the handling activity and obtain a USEPA Identification Number.
Handlers are allowed to crush lamps only on the generator’s site for volume reduction. There are requirements for the type of crushing equipment, ambient air mercury concentrations in the crushing area, training of personnel involved in the crushing, and quarterly reports to the IEPA on the crushing activity. The regulation prohibits handlers from gathering lamps from various generator sites and crushing them at a central location. i.e. Lamps must be crushed at the site from which they were generated (removed from the fixture).


Transporters must transport the lamps only to a universal waste handling facility or a universal waste destination facility such as Fluorecycle, Inc. Transporters are allowed to crush lamps for volume reduction under the same restrictions noted for handlers, i.e. only on the generator site.

Destination Facilities

The destination facility must render all hazardous components of the lamps into directly re-useable products. For example, a process that simply separates the lamp components into end caps, glass, and mercury-containing phosphor powder is not recycling. The Fluorecycle, Inc. facility incorporates a distillation process to remove the mercury from the phosphor powder so it can be sold directly to a mercury manufacturer for use in new mercury-containing devices.

Fluorecycle, Inc. is a state-of-the-art lamp recycling facility using Swedish manufactured equipment. This facility meets or exceeds all regulatory requirements. We have worked closely with the IEPA, to ensure our facility not only complies with the letter of the regulations, but also with IEPA’s intent and vision of a recycling program. Our efforts have been instrumental in helping the IEPA define their spent mercury-containing lamp management policy.

We would like to work with you to set up your lamp management program and to become your lamp recycling facility.

Please call us at 815-363-4411 to discuss how we can help you with your lamp management efforts.

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